Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Validity of draft assessment order passed u/s 143(3) r.w.s. 144 r.w.s. 144C(1) - reference to DRP - the final assessment order was passed by the AO on 19.12.2017 and served the same to the assessee on 21.12.2017. Therefore assessee has an option to challenge the final assessment order before the CIT(A) in accordance with law. Therefore no merits in the grounds raised by the assessee. The present appeal filed by the assessee is devoid of merits and against the provisions of section 144C (2)(b)(ii). Therefore the appeal filed by the Assessee is hereby dismissed. - AT
Validity of draft assessment order passed u/s 143(3) r.w.s. 144 r.w.s. 144C(1) - reference to DRP - the final assessment order was passed by the AO on 19.12.2017 and served the same to the assessee on 21.12.2017. Therefore assessee has an option to challenge the final assessment order before the CIT(A) in accordance with law. Therefore no merits in the grounds raised by the assessee. The present appeal filed by the assessee is devoid of merits and against the provisions of section 144C (2)(b)(ii). Therefore the appeal filed by the Assessee is hereby dismissed. - AT
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